EACPHS Background Screening Policy

I.    Policy: 

The Eugene Applebaum College of Pharmacy and Health Sciences (EACPHS) requires background screening for applicants to all of its degree programs as part of the admission process, as well as for admitted students, prior to starting clinical rotations and annually thereafter.   

II.    Applicability:

The Health Science Division of the Eugene Applebaum College of Pharmacy and Health Sciences, and its students. 

III.    Procedure: 

a.    Applicants:

i.    Applicants for admission to a program will be required to disclose the following on their application for admission: (i) any criminal and/or arrest record; (ii) whether or not they are listed on a state or federal Sexual Offender Registry and/or Child Abuse and Neglect Registry; (iii) any history of government sanction or exclusion related to health care or federal grants or awards; and (iv) any history of negative action taken on any occupational license. 

ii.    Conditionally Accepted Applicants will be required to undergo background screening prior to matriculation, which will include at least the following: 

1.    Criminal background search to include current and previous states and/or counties of residence and employment in the preceding 7 years;

2.    Sexual Offender Registry (State and Federal)

3.    HHS/OIG/SAM Exclusion Database

Programs may require additional areas of screening as necessary.

iii.    All expenses related to applicant-stage background screening will be the responsibility of the applicant. 

iv.    Results of the applicant's background screening will be shared with the applicant and the program director and/or director of clinical education for the relevant program, and may also be shared with the relevant Department Chair and/or Dean. 

v.    If the background screening reveals any Negative Findings, the applicant's conditional acceptance may be revoked. Before any such negative action is taken, however, the applicant will have an opportunity to provide additional information regarding the screening results, and the program's admission committee (not including any external, non-WSU-employed members of the admission committee) and program director (and/or director of clinical education) will undertake an individualized review of the totality of the circumstances presented by the background screening results and the applicant. 

b.    Admitted Students:

i.    Admitted students may be required to undergo additional background screening prior to engaging in clinical experiences / rotations, and annually thereafter, all as required by the relevant degree program. 

ii.    Background screening required at the clinical experience stage will vary in substance based on the requirements of the clinical site, but may include some or all of the following:

1.    Social Security number verification;

2.    Criminal background search to include current and previous states and/or counties of residence and employment in the preceding 7 years;

3.    Sexual Offender Registry (State and Federal)

4.    Michigan Child Abuse & Neglect Registry

5.    HHS/OIG/SAM Exclusion Databases

iii.    All expenses related to background screening at the clinical-experience stage (and all subsequent annual re-screenings) will be the responsibility of the Student. 

iv.    Results of the student's background screening will be shared with the student and the relevant program director and/or director of clinical education, and may also be shared with the relevant Department Chair and/or Dean. Results will be shared with the clinical site only if the student consents, as required by applicable law, including the Fair Credit Reporting Act (FCRA); provided, however, that failure to consent will disqualify the student from rotating at the relevant clinical site, which may make it impossible for the student to complete the degree program. 

v.    If the background screening reveals any Negative Findings, the student may be prohibited from participating in clinical rotations that are required to complete their degree program. Before this or any other adverse action is taken, however, the student will have an opportunity to provide additional information regarding the screening results, and the relevant program director and/or director of clinical education, in conjunction with the clinical site, will undertake an individualized review of the totality of the circumstances presented by the background screening results and the student. It is important to note that, in some cases, the clinical site is the party that will make final determinations about student eligibility to rotate, and that their decision will be based on their unique standards and policies. 

c.    Ongoing Duty to Self-Report:

i.    Admitted students have an ongoing duty to report criminal convictions, pending charges, or other information that is of the nature or type that might show up on any background screening report described in this policy. The report shall be made to the program director and/or director of clinical education.  This ongoing duty continues even if the Student has successfully passed all previous background screenings at the applicant stage, and the clinical experience stage.

Student self-reported events will be evaluated by the program director and/or director of clinical education and may (depending on the nature of the event and the requirements of the contract with the clinical site) be subject to the process described in Section II(b)(v), above. 

IV.    Definitions: 

a.    Conditionally Accepted Applicants: Applicants who have been accepted to the relevant degree program pending, among other things, satisfactory background screening results. 

b.    Negative Findings: Any background screening finding that may negatively impact an Applicant or Student's ability to: (i) participate in clinical rotations that are necessary to complete their degree program; or (ii) obtain a professional license related to the degree program. Screening results that will qualify as "Negative Findings" will, in part, be defined by the policies of the clinical rotation site.